Porter v. Dartmouth College, et al.

2010 DNH 008
CourtDistrict Court, D. New Hampshire
DecidedJanuary 12, 2010
DocketCV-07-28-JL
StatusPublished

This text of 2010 DNH 008 (Porter v. Dartmouth College, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Porter v. Dartmouth College, et al., 2010 DNH 008 (D.N.H. 2010).

Opinion

Porter v . Dartmouth College, et a l . CV-07-28-JL 1/12/10 P UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Christina M . Porter, Deceased, by Brent M . Porter and Mary M . Salstrom, As Administrators of Civil N o . 07-cv-28-JL Her Estate and Individually Opinion N o . 2010 DNH 008

v.

Dartmouth College, et a l .

OPINION AND ORDER

The question before the court is whether this wrongful death

case must be dismissed because the plaintiffs, who brought suit

three years ago claiming to be the administrators of their

daughter’s estate, were not actually appointed as administrators

until six months ago, after the statute of limitations expired.

The defendant, Dartmouth College, has moved to dismiss for lack

of standing, see Fed. R. Civ. P. 12(b)(6), arguing that timely

appointment is required for an administrator to maintain a

wrongful death action under New Hampshire law. The plaintiffs

argue that they cured their good-faith mistake by ultimately

becoming administrators and that their case should not be

dismissed on a “technicality.”

This court has subject-matter jurisdiction under 28 U.S.C.

§ 1332(a)(1) (diversity). After oral argument, Dartmouth’s

motion is denied. Although the plaintiffs may not have strictly

complied with the wrongful death and survival statute, see N.H.

Rev. Stat. §§ 556:9 et seq., the New Hampshire Supreme Court has “given [the statute] a liberal interpretation, so as to fully

protect the rights of those interested in the estate.” Owen v .

Owen, 109 N.H. 5 3 4 , 536 (1969) (quoting Halle v . Cavanaugh, 79

N.H. 4 1 8 , 420 (1920)). This court, applying New Hampshire law,

must do the same. The relevant case law from the New Hampshire

Supreme Court suggests that the plaintiffs should be allowed to

proceed to trial now that they have been appointed as

administrators of their daughter’s estate.

I. Applicable legal standard

For purposes of ruling on Dartmouth’s motion to dismiss,

this court must accept the plaintiffs’ well-pleaded facts as true

and must draw all reasonable inferences in their favor. Phoung

Luc v . Wyndham Mgmt. Corp., 496 F.3d 8 5 , 88 (1st Cir. 2007).

Because the motion challenges the plaintiffs’ capacity to

maintain suit on behalf of their daughter’s estate, it is

governed by “the law of the state where the court is located.”

Fed. R. Civ. P. 17(b)(3); see also Martel v . Stafford, 992 F.2d

1244 (1st Cir. 1993) (applying forum state’s law in determining

administrator’s capacity). In applying New Hampshire law, this

court is “bound by the teachings of the state’s highest court.”

Phoung Luc, 496 F.3d at 8 8 . To the extent that the New Hampshire

Supreme Court “has not definitively weighed in,” this court “may

consider analogous decisions, considered dicta,” and other

2 reliable sources in making an “informed prophecy” about how that

court would resolve the issue. Janney Montgomery Scott LLC v .

Tobin, 571 F.3d 1 6 2 , 164 (1st Cir. 2009).1

II. Background

Christina Porter, a sophomore at Dartmouth College, suffered

catastrophic injuries while participating in the school’s

introductory ski class at the Dartmouth Skiway on February 3 ,

2004. After nearly a year of medical care, she ultimately died

from the injuries on January 1 6 , 2005. At the time of her death,

she was 21 years old with no spouse, no children, no siblings, no

will, and no tangible assets other than her portfolio of artwork

from grade school to college. Her closest living relatives were

her parents, plaintiffs Brent Porter and Mary Salstrom.

1 The plaintiffs also try to invoke federal law by moving to supplement their complaint with a paragraph describing their appointment as administrators, see Fed. R. Civ. P. 15(d), and then arguing that the paragraph relates back to the time of filing under Fed. R. Civ. P. 15(c). It is true that “Rule 15(c) applies in a diversity case notwithstanding the incidence of a more restrictive state rule.” Morel v . DaimlerChrysler AG, 565 F.3d 2 0 , 25 (1st Cir. 2009). But if state law is less restrictive, then it automatically controls. See id. at 2 6 . Because New Hampshire law applies by virtue of Rule 17(b)(3) and allows this case to go forward, see infra Part I I I , this court need not conduct a separate analysis under Rule 15(c). The plaintiffs’ motion for leave to file an amended/supplemented complaint, see document n o . 9 5 , will be resolved in due course after briefing has been completed.

3 The plaintiffs filed this lawsuit against Dartmouth on

February 2 , 2007, just before the three-year anniversary of their

daughter’s accident. They asserted claims for wrongful death and

negligence under New Hampshire law, both individually and as

purported administrators of their daughter’s estate. Dartmouth

initially moved to dismiss the case as barred by the New

Hampshire Ski Statute. See N.H. Rev. Stat. § 225-A:24 (giving

ski area operators limited immunity against personal injury

claims that result from the inherent risks of skiing). The court

denied the motion, but noted that because their daughter was an

adult, the plaintiffs could not maintain individual claims for

loss of consortium. See Porter v . Dartmouth Coll., 2007 DNH 1 3 1 ,

7-8 n.3 (Barbadoro, D . J . ) .

Two years into the case, with discovery still underway,

Dartmouth asked the plaintiffs for a copy of their estate

administration papers, which it needed to obtain confidential

medical records from their daughter’s medical providers. In

attempting to satisfy that request, plaintiffs’ counsel learned

in May 2009 that neither the plaintiffs nor anyone else had ever

sought appointment as administrators of their daughter’s estate.

The plaintiffs mistakenly believed that, as surviving parents,

they became administrators automatically when their daughter died

without a will.2

2 Both plaintiffs have filed affidavits regarding their mistaken belief. At oral argument, plaintiffs’ counsel took

4 Hoping to rectify this good-faith mistake, the plaintiffs

immediately began the process of seeking appointment as

administrators from the probate court in Kings County (Brooklyn),

New York, where they and their daughter resided at the time of

her death. In the meantime, Dartmouth moved to dismiss this case

for lack of standing. Two weeks later, on July 2 1 , 2009, the

plaintiffs finally obtained letters of administration from the

probate court.

As briefing continued on the motion to dismiss, the court

denied Dartmouth’s previously submitted motions for summary

judgment, leaving the case on track for a February 2010 trial.

See Porter v . Dartmouth Coll., 2009 DNH 145 (Barbadoro, D.J.)

(denying summary judgment motion relating to liability release

agreement); margin order dated Aug. 1 9 , 2009 (Barbadoro, D.J.)

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2010 DNH 008, Counsel Stack Legal Research, https://law.counselstack.com/opinion/porter-v-dartmouth-college-et-al-nhd-2010.